Gnoyr MoNrnH* food Hlcy 0odttloa February 3,2015 Chairman Ryan Lynch Economic Affa irs lnterim Committee Submitted via e-mail Dear Chairman Lynch and Committee Members, The Grow Montana Food Policy coalition is a broad-based coalition dedicated to promoting policies that support sustainable Montana-owned food production, processing, and distribution with the goal of improving all community members' access to healthy Montana foods. we are deeply concerned about the Department of Livestock's proposed amendment to ARM 32.2.406. we urge the committe€ to continue delaying the implementation of the rule and ask that it work with the department to identify and secure other sources of funding for inspection fees. The amendment negatively impacts the dairy industry in Montana, especially the smaller dairy producers and processors. The proposed inspection fee per 100 pounds for producers almost doubles, and the minimum monthly charge increases from 550 to 5225. Fees for dairy processors are also included in the proposed amendment, with a minimum monthly charge of s725 and a maximum of 52,850. The impact on small dairy businesses could be severe. These increased fees will be a burden to small producers, and it is likely that it will result in some of these operations having to shut down. Some ofthese producers discussed this in their comments at the public hearing held last week by the department on the proposal, where not one person or business spoke in favor of the policy change. lf small operations go out of business dueto increased monetary cost, the processors that are able to continue operating may have to purchase milk outside the state, which will have a direct impact on Montana's dairy industry as a whole. Potentially the most disturbing aspect of the department considering this proposal is that it recognizes the negative impact on small producers and processors. The "Notice of proposed Amendment,, Jeclares that the Department of Livestock has "determined that the fee increase in the proposed amendment may significantly and directly impact some small businesses." Furthermore, Livestock states, ,,small businesses in the early growth state will be especially impacted." These statements should have given the department pause and made it take more time to involve impacted stakeholders, while it also- examined other potential waysto increase revenue. Duringthe public hearing lastweek, multiple producers discussed howthey had benefited from the Montana Department of Agriculture,s,,Growth Through Ag" program, receiving grants and loans to herp start and grow their businesses. These The Grow Montono Food Policy codlition is o brood-bosed coolition whose common purpose is to promote comhunjty economic development ond educotion policies thot suppott sustoinoble Montono-owned food ptoduction, processinql ond dirtiitrtion which ifiproves oll Montonons' occess to heolthy Montono Joods. Housed ot dnd coordinoted by the Butte-bosed Notionot center for App.opriote Technology, the orgonizotions compising Grow Mootono's steerinq committee dre Altemotive Eoeryy Resources orgonizotion (Helenol, community Food ond Agticultute cootition (Missoulo), Loke county conmunity oevetopient corporolion (Ronon), Montono Acodemy of Nutrition ond Dietetics (Bozemon), Montono Formers union (Grcot Fotts), Montono olfice of Public lnstruction (Heleno), Ndtionol center fol Appropriote fechnology (Butte), ond Nofthern ploins Resource counrcil (Bi inqs).
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Gnoyr MoNrnH* · Gnoyr MoNrnH* food Hlcy 0odttloa February 3,2015 Chairman Ryan Lynch Economic Affa irs lnterim Committee Submitted via e-mail Dear Chairman Lynch and Committee Members,
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Gnoyr MoNrnH*food Hlcy 0odttloa
February 3,2015
Chairman Ryan LynchEconomic Affa irs lnterim Committee
Submitted via e-mail
Dear Chairman Lynch and Committee Members,
The Grow Montana Food Policy coalition is a broad-based coalition dedicated to promoting policies thatsupport sustainable Montana-owned food production, processing, and distribution with the goal ofimproving all community members' access to healthy Montana foods. we are deeply concerned aboutthe Department of Livestock's proposed amendment to ARM 32.2.406. we urge the committe€ tocontinue delaying the implementation of the rule and ask that it work with the department to identifyand secure other sources of funding for inspection fees.
The amendment negatively impacts the dairy industry in Montana, especially the smaller dairyproducers and processors. The proposed inspection fee per 100 pounds for producers almost doubles,and the minimum monthly charge increases from 550 to 5225. Fees for dairy processors are alsoincluded in the proposed amendment, with a minimum monthly charge of s725 and a maximum of52,850. The impact on small dairy businesses could be severe.
These increased fees will be a burden to small producers, and it is likely that it will result in some ofthese operations having to shut down. Some ofthese producers discussed this in their comments at thepublic hearing held last week by the department on the proposal, where not one person or businessspoke in favor of the policy change. lf small operations go out of business dueto increased monetarycost, the processors that are able to continue operating may have to purchase milk outside the state,which will have a direct impact on Montana's dairy industry as a whole.
Potentially the most disturbing aspect of the department considering this proposal is that it recognizesthe negative impact on small producers and processors. The "Notice of proposed Amendment,, Jeclaresthat the Department of Livestock has "determined that the fee increase in the proposed amendmentmay significantly and directly impact some small businesses." Furthermore, Livestock states, ,,small
businesses in the early growth state will be especially impacted." These statements should have giventhe department pause and made it take more time to involve impacted stakeholders, while it also-examined other potential waysto increase revenue. Duringthe public hearing lastweek, multipleproducers discussed howthey had benefited from the Montana Department of Agriculture,s,,GrowthThrough Ag" program, receiving grants and loans to herp start and grow their businesses. These
The Grow Montono Food Policy codlition is o brood-bosed coolition whose common purpose is to promote comhunjty economicdevelopment ond educotion policies thot suppott sustoinoble Montono-owned food ptoduction, processinql ond dirtiitrtionwhich ifiproves oll Montonons' occess to heolthy Montono Joods. Housed ot dnd coordinoted by the Butte-bosed Notionotcenter for App.opriote Technology, the orgonizotions compising Grow Mootono's steerinq committee dre Altemotive EoeryyResources orgonizotion (Helenol, community Food ond Agticultute cootition (Missoulo), Loke county conmunity oevetopientcorporolion (Ronon), Montono Acodemy of Nutrition ond Dietetics (Bozemon), Montono Formers union (Grcot Fotts), Montonoolfice of Public lnstruction (Heleno), Ndtionol center fol Appropriote fechnology (Butte), ond Nofthern ploins Resource counrcil(Bi inqs).
producers face a perplexing situation where one state agency is helping their businesses, while anotheris proposing changes that may eliminate them.
Fhe Bozemon Doily Chronicle ran an article in November 2015 (a copy of which is attached to this letter)quotin8 only a portion of the 72 people the "Notice" says will be impacted; however, it is clear that the
danger to these operations is real. The article reinforces testimony given lastweekatthe public
hearing. One local producer and processor predicted the increased inspection fees would cost her an
additional 59,000 each year. Small dairy operations are part of the small business engine that drivesMontana's economy. The Department of Livestock should be seeking to help these dairy producers andprocessors strive, not implementing fees that could lead to their demise.
We encourage the Economic Affairs lnterim Committee to continue opposing the proposed changes toARM 32.2.406. We also encourage the committee to work with the department to explore potentialpolicy changes that could make more of the milk inspection budget come from the state's General Fund,
since the need for health and safety inspections are a public health issue.
Sincerely,
16r- 5 NlAAa.,"^-/
Travis McAdamGrow Montana CoordinatorNational center for Appropriate Technology